Subject: Impact of climate change on company's operations vs Impact of company's operations on climate change
From: Ertan Kucukyalcin
Affiliation:

Aug. 21, 2021





Dear Ms. Allison Herren Lee;
U.S. Securities and Exchange Commission
 
Thank you for giving me the opportunity to comment on the "Climate Change Disclosures".
 
An increase in sea-levels may financially impact a company. On the other hand CO2 emissions of a company may impact the environment. While the two statements may look alike, they are different and they have differing consequences. Therefore they should be addressed separately. 
 
The first is -mainly- about the interests of shareholders, as it directly impacts the financial results and risks of the company. Second is -mainly- about the wider stakeholder group, such as coastal societies  ( i.e https://www.bloomberg.com/news/articles/2020-02-03/mapping-migration-in-the-face-of-climate-change ).
 
 
In order to avoid this ambiguity, I recommend making an explicit distinction between,
 
* Impacts of climate change on a company's operations and
* Impacts of company's operations on climate change.
 
 
Such a distinction will allow companies, as well as shareholders, stakeholders and regulators, to assess the two differing cause and effect flow in a better structured way.
 
 
Furthermore, I recommend that the reporting of those two perspectives should be done in two separate sections in a report.
 
Once again, thank you for giving this opportunity to comment.
 
Kind regards,

Ertan Kucukyalcin
Istanbul